FERC Filings

MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Bangor Hydro-Electric Company, Central Maine Power Company, National Grid USA, Northeast Utilities Service Company, The United Illuminating Company, Vermont Electric Power Company, ISO N

III. CONCLUSION

NERTO does not meet the Commission’s requirements (1) that an RTO be independent of market participants, (2) with respect to scope and regional configuration, (3) as to interconnection of generators with the transmission grid, (4) with respect to the calculation of transmission capability, (5) with respect to market monitoring, and (6) with respect to interregional coordination. The Commission should not accept Petitioners’ Compliance Filing and Petitioners should be directed to amend their Compliance Filing in a manner consistent with the issues raised by EPSA in this Protest. In particular, the Commission should direct the three northeastern ISOs to adopt the best market rules and business practices of the three ISOs and should specify practical measures, such as involvement of the Commission’s ADR unit and a settlement judge, to require the three ISOs to integrate the market functions and subsequently the ISOs’ structures. The Commission should issue an order immediately directing that such a regional integration effort commence.

February 22, 2001

Respectfully submitted,

Julie Simon, Vice President of Policy
Mark Bennett, Senior Manager of Policy
Electric Power Supply Association
1401 H Street, N.W., Suite 760
Washington, D.C. 20005

Larry F. Eisenstat
Michael J. Rustum
Charles M. Pratt
Dickstein Shapiro Morin & Oshinsky, LLP
2101 L Street, N.W.
Washington, D.C. 20037

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